AuditORIA LAKE SHORE GOLD

Publicado el 15 de marzo de 2021

Como sabrá, la Agencia de Ingresos de Canadá (CRA, por sus siglas en inglés) ha vuelto a evaluar a Lake Shore Gold Corp. (nuestra subsidiaria) para negar ciertos gastos de exploración canadienses (CEE, por sus siglas en inglés) incurridos en 2014 y 2015. La reevaluación de la CRA reduce la cantidad de CEE a la que se renunció vigente para Ud. a partir del 31 de diciembre de 2014.

Aunque estamos disputando activamente la propuesta de la CRA, la CRA ha indicado que comenzará a enviar Avisos de Reevaluación a los suscriptores afectados.

Este sitio web contiene información y procedimientos importantes que debe seguir cuando recibe un Aviso de Reevaluación. El mismo se divide en tres secciones. Solicitamos que lea atentamente y siga las instrucciones establecidas en la sección que se aplica a usted.

Si ninguna de las secciones se aplica a usted, o si tiene más preguntas sobre la información y los procedimientos, comuníquese con su asesor legal o fiscal.

Actualización el 15 de febrero de 2022

A modo de actualización, impugnamos la propuesta de la CRA mediante la presentación de una Notificación de Objeción el 21 de julio de 2021. La propuesta de la CRA permanece en disputa activa con la CRA. Si escucha lo contrario de cualquier fuente, incluida la CRA, por favoar diríjalos a este sitio web para obtener una aclaración.

Aviso de procedimientos de reevaluación de Lake Shore Gold

  • Applies to individuals that subscribed for units of a flow-though limited partnership and received CEE renunciations indirectly through the limited partnership. These individuals would have received a T5013 Slip indicating the renounced amount.

    The reduction in CEE renounced to individuals that subscribed for units of a flow-though limited partnership will lead to a reassessment of their 2014 taxation year and/or one or more subsequent taxation years.

    When you receive a Notice of Reassessment from the CRA, you should file a Notice of Objection within 90 days of the date noted on the Notice of Reassessment. We expect that your appeal will be held in abeyance pending the outcome of our dispute with the CRA relating to the CEE that was denied.

    The appeals process will take some time to resolve, so we encourage you to pay the accrued tax and interest noted on the Notice of Reassessment – this will stop interest from accumulating on the outstanding balance during the appeals process.

    If Lake Shore Gold Corp. is partially or entirely successful in its dispute with the CRA and you file a Notice of Objection within the 90 day window, you should receive:

    (i)   a consequential Notice of Reassessment restoring all or a portion of the CEE renounced effective December 31, 2014;

    (ii)  a refund of some or all of the tax and interest you paid in connection with the original Notice of Reassessment; and

    (iii) an additional payment of interest if you paid the original Notice of Reassessment.

    Individuals who do not file a Notice of Objection within the 90 day window will not be entitled to receive a consequential reassessment, refund or interest payment even if Lake Shore Gold Corp. is partially or entirely successful in its dispute with the CRA.  In addition, such individuals will not be entitled to an indemnity for taxes paid or payable under the original Notice of Reassessment.

    Individuals may object by filing a Notice of Objection in a T400A Form – the link to that form is here*. Please fill out the T400A Form with your own personal information according to the instructions. In the box where it asks you to provide the issues, reasons, and all relevant facts for your objection, please include the following language:

    I hereby object to the amounts assessed, penalties and interest and any consequential adjustments in their entirety.  Further facts, reasons and supporting documentation will be provided to an Appeals Officer, as necessary, once one is assigned.

    I request that this Notice of Objection be assigned to the same Appeals Officer as is handling the related Notices of Objection being filed by Lake Shore Gold Corp. (BN 12556 4005) for its 2014 and 2015 taxation years (the “Lake Shore Objections”).  These Objections all relate to the tax treatment of CEE arising out of the same facts.

    I also request that this Notice of Objection be held in abeyance pending resolution of the Lake Shore Objections as I understand that the result of the Lake Shore Objections will impact my dispute.

    You should include a cover letter with your T400A Form – a link to a sample cover letter is here. If you file a Notice of Objection as instructed, we expect the CRA will make the necessary consequential reassessments of your income tax returns if Lake Shore Gold Corp. is partially or entirely successful with its dispute. The second page of the T400A Form explains how to submit your Notice of Objection to the CRA.

  • Applies to corporations that subscribed for units of a flow-though limited partnership and received CEE renunciations indirectly through the limited partnership. These corporations would have received a T5013 Slip indicating the renounced amount.

    The reduction in CEE renounced to corporations that subscribed for units of a flow-though limited partnership will lead to a reassessment of their taxation year that includes the effective date of renunciation and/or one or more subsequent taxation years. The reduction in CEE renounced to corporations that subscribed for units of a flow-though limited partnership will lead to a reassessment of their taxation year that includes the effective date of renunciation and/or one or more subsequent taxation years.

    When you receive a Notice of Reassessment from the CRA, you should file a Notice of Objection within 90 days of the date noted on the Notice of Reassessment. We expect that your appeal will be held in abeyance pending the outcome of our dispute with the CRA relating to the CEE that was denied.

    The appeals process will take some time to resolve, so we encourage you to pay the accrued tax and interest noted on the Notice of Reassessment – this will stop interest from accumulating on the outstanding balance during the appeals process.

    If Lake Shore Gold Corp. is partially or entirely successful in its dispute with the CRA and you file a Notice of Objection within the 90 day window, you should receive:

    (i) a consequential Notice of Reassessment restoring all or a portion of the CEE renounced effective December 31, 2014;

    (ii) a refund of some or all of the tax and interest you paid in connection with the original Notice of Reassessment; and

    (iii) an additional payment of interest if you paid the original Notice of Reassessment.

    Corporations who do not file a Notice of Objection within the 90 day window will not be entitled to receive a consequential reassessment, refund or interest payment even if Lake Shore Gold Corp. is partially or entirely successful in its dispute with the CRA.  In addition, such corporations will not be entitled to an indemnity for taxes paid or payable under the original Notice of Reassessment.

    Corporations may object by filing a Notice of Objection in a T400A Form – the link to that form is here*. Please fill out the T400A Form with your information according to the instructions. In the box where it asks you to provide the issues, reasons, and all relevant facts for your objection, please include the following language:

    [Name of corporation] hereby objects to the amounts assessed, penalties and interest and any consequential adjustments in their entirety.  Further facts, reasons and supporting documentation will be provided to an Appeals Officer, as necessary, once one is assigned.

    [Name of corporation] requests that this Notice of Objection be assigned to the same Appeals Officer as is handling the related Notices of Objection being filed by Lake Shore Gold Corp. (BN 12556 4005) for its 2014 and 2015 taxation years (the “Lake Shore Objections”).  These Objections all relate to the tax treatment of CEE arising out of the same facts.

    [Name of corporation] also requests that this Notice of Objection be held in abeyance pending resolution of the Lake Shore Objections as it understands that the result of the Lake Shore Objections will impact its dispute.

    You should include a cover letter with your T400A Form – a link to a sample cover letter is here. If you file a Notice of Objection as instructed, we expect the CRA will make the necessary consequential reassessments of your income tax returns if Lake Shore Gold Corp. is partially or entirely successful with its dispute. The second page of the T400A Form explains how to submit your Notice of Objection to the CRA.

  • Applies to corporations that subscribed for flow-through shares of Lake Shore Gold Corp. and received CEE renunciations directly.  These corporations would have received a Form T101 indicating the renounced amount.

    The reduction in CEE renounced to subscribers that are corporations will lead to a reassessment of their taxation year that includes the effective date of renunciation and/or one or more subsequent taxation years. The reduction in CEE renounced to subscribers that are corporations will lead to a reassessment of their taxation year that includes the effective date of renunciation and/or one or more subsequent taxation years.

    When you receive a Notice of Reassessment from the CRA, you should file a Notice of Objection within 90 days of the date noted on the Notice of Reassessment. We expect that your appeal will be held in abeyance pending the outcome of our dispute with the CRA relating to the CEE that was denied.

    The appeals process will take some time to resolve, so we encourage you to pay the accrued tax and interest noted on the Notice of Reassessment – this will stop interest from accumulating on the outstanding balance during the appeals process.

    If Lake Shore Gold Corp. is partially or entirely successful in its dispute with the CRA and you file a Notice of Objection within the 90 day window, you should receive:

    (i) a consequential Notice of Reassessment restoring all or a portion of the CEE renounced effective December 31, 2014;

    (ii) a refund of some or all of the tax and interest you paid in connection with the original Notice of Reassessment; and

    (iii) an additional payment of interest if you paid the original Notice of Reassessment.

    Subscribers who do not file a Notice of Objection within the 90 day window will not be entitled to receive a consequential reassessment, refund or interest payment even if Lake Shore Gold Corp. is partially or entirely successful in its dispute with the CRA.  In addition, such subscribers will not be entitled to an indemnity for taxes paid or payable under the original Notice of Reassessment.

    Subscribers may object by filing a Notice of Objection in a T400A Form – the link to that form is here*. Please fill out the T400A Form with your information according to the instructions. In the box where it asks you to provide the issues, reasons, and all relevant facts for your objection, please include the following language:

    [Name of corporation] hereby objects to the amounts assessed, penalties and interest and any consequential adjustments in their entirety.  Further facts, reasons and supporting documentation will be provided to an Appeals Officer, as necessary, once one is assigned.

    [Name of corporation] requests that this Notice of Objection be assigned to the same Appeals Officer as is handling the related Notices of Objection being filed by Lake Shore Gold Corp. (BN 12556 4005) for its 2014 and 2015 taxation years (the “Lake Shore Objections”).  These Objections all relate to the tax treatment of CEE arising out of the same facts.

    [Name of corporation] also requests that this Notice of Objection be held in abeyance pending resolution of the Lake Shore Objections as it understands that the result of the Lake Shore Objections will impact its dispute.

    You should include a cover letter with your T400A Form – a link to a sample cover letter is here. If you file a Notice of Objection as instructed, we expect the CRA will make the necessary consequential reassessments of your income tax returns if Lake Shore Gold Corp. is partially or entirely successful with its dispute. The second page of the T400A Form explains how to submit your Notice of Objection to the CRA.

AudiTORIA TEMEX RESOURCES

Publicado el 23 de marzo de 2021
Como sabrá, la Agencia de Ingresos de Canadá (CRA, por sus siglas en inglés) ha reevaluado a Temex Resources Corp. para negar ciertos gastos de exploración canadienses (CEE, por sus siglas en inglés) incurridos en 2014 y 2015. La reevaluación de la CRA reduce la cantidad de CEE que se le renunció a partir del 31 de diciembre , 2014. Temex Resources Corp. es un predecesor de nuestra subsidiaria Lake Shore Gold Corp. Aunque estamos disputando activamente la propuesta de la CRA, la CRA ha indicado que comenzará a enviar Avisos de Reevaluación a los suscriptores afectados.
Este sitio web contiene información y procedimientos importantes que debe seguir cuando recibe un Aviso de Reevaluación. El mismo se divide en tres secciones. Le pedimos que lea atentamente y siga las instrucciones establecidas en la sección que se aplica a usted.
Si ninguna de las secciones se aplica a usted, o si tiene más preguntas sobre la información y los procedimientos, comuníquese con su asesor legal o fiscal.
Actualización el 15 de febrero de 2022
A modo de actualización, impugnamos la propuesta de la CRA mediante la presentación de una Notificación de Objeción el 4 de noviembre de 2021. La propuesta de la CRA permanece en disputa activa con la CRA. Si escucha lo contrario de cualquier fuente, incluida la CRA, diríjalos a este sitio web para obtener una aclaración.

Temex Resources Aviso de Procedimientos de Reevaluación

  • Applies to individuals that subscribed for units of a flow-though limited partnership and received CEE renunciations indirectly through the limited partnership. These individuals would have received a T5013 Slip indicating the renounced amount.

    The reduction in CEE renounced to individuals that subscribed for units of a flow-though limited partnership will lead to a reassessment of their 2014 taxation year and/or one or more subsequent taxation years.

    When you receive a Notice of Reassessment from the CRA, you should file a Notice of Objection within 90 days of the date noted on the Notice of Reassessment. We expect that your appeal will be held in abeyance pending the outcome of our dispute with the CRA relating to the CEE that was denied.

    The appeals process will take some time to resolve, so we encourage you to pay the accrued tax and interest noted on the Notice of Reassessment – this will stop interest from accumulating on the outstanding balance during the appeals process.

    If Temex Resources Corp. is partially or entirely successful in its dispute with the CRA and you file a Notice of Objection within the 90 day window, you should receive:

    (i)   a consequential Notice of Reassessment restoring all or a portion of the CEE renounced effective December 31, 2014;

    (ii)  a refund of some or all of the tax and interest you paid in connection with the original Notice of Reassessment; and

    (iii) an additional payment of interest if you paid the original Notice of Reassessment.

    Individuals who do not file a Notice of Objection within the 90 day window will not be entitled to receive a consequential reassessment, refund or interest payment even if Temex Resources Corp. is partially or entirely successful in its dispute with the CRA.  In addition, such individuals will not be entitled to an indemnity for taxes paid or payable under the original Notice of Reassessment.

    Individuals may object by filing a Notice of Objection in a T400A Form – the link to that form is here. Please fill out the T400A Form with your own personal information according to the instructions. In the box where it asks you to provide the issues, reasons, and all relevant facts for your objection, please include the following language:

    I hereby object to the amounts assessed, penalties and interest and any consequential adjustments in their entirety.  Further facts, reasons and supporting documentation will be provided to an Appeals Officer, as necessary, once one is assigned.

    I request that this Notice of Objection be assigned to the same Appeals Officer as is handling the related Notices of Objection being filed by in response to the Temex Resources Corp. (BN 88941 3084) reassessments for its 2014 and 2015 taxation years (the “Temex Objections”). These Objections all relate to the tax treatment of CEE arising out of the same facts.

    I also request that this Notice of Objection be held in abeyance pending resolution of the Temex Objections as I understand that the result of the Temex Objections will impact my dispute.

    You should include a cover letter with your T400A Form – a link to a sample cover letter is here*. If you file a Notice of Objection as instructed, we expect the CRA will make the necessary consequential reassessments of your income tax returns if Temex Resources Corp. is partially or entirely successful with its dispute. The second page of the T400A Form explains how to submit your Notice of Objection to the CRA.

  • Applies to corporations that subscribed for units of a flow-though limited partnership and received CEE renunciations indirectly through the limited partnership. These corporations would have received a T5013 Slip indicating the renounced amount.

    The reduction in CEE renounced to corporations that subscribed for units of a flow-though limited partnership will lead to a reassessment of their taxation year that includes the effective date of renunciation and/or one or more subsequent taxation years.

    When you receive a Notice of Reassessment from the CRA, you should file a Notice of Objection within 90 days of the date noted on the Notice of Reassessment. We expect that your appeal will be held in abeyance pending the outcome of our dispute with the CRA relating to the CEE that was denied.

    The appeals process will take some time to resolve, so we encourage you to pay the accrued tax and interest noted on the Notice of Reassessment – this will stop interest from accumulating on the outstanding balance during the appeals process.

    If Temex Resources Corp. is partially or entirely successful in its dispute with the CRA and you file a Notice of Objection within the 90 day window, you should receive:

    (i) a consequential Notice of Reassessment restoring all or a portion of the CEE renounced effective December 31, 2014;

    (ii) a refund of some or all of the tax and interest you paid in connection with the original Notice of Reassessment; and

    (iii) an additional payment of interest if you paid the original Notice of Reassessment.

    Corporations who do not file a Notice of Objection within the 90 day window will not be entitled to receive a consequential reassessment, refund or interest payment even if Temex Resources Corp. is partially or entirely successful in its dispute with the CRA.  In addition, such corporations will not be entitled to an indemnity for taxes paid or payable under the original Notice of Reassessment.

    Corporations may object by filing a Notice of Objection in a T400A Form – the link to that form is here*. Please fill out the T400A Form with your information according to the instructions. In the box where it asks you to provide the issues, reasons, and all relevant facts for your objection, please include the following language:

    [Name of corporation] hereby objects to the amounts assessed, penalties and interest and any consequential adjustments in their entirety.  Further facts, reasons and supporting documentation will be provided to an Appeals Officer, as necessary, once one is assigned.

    [Name of corporation] requests that this Notice of Objection be assigned to the same Appeals Officer as is handling the related Notices of Objection being filed in response to the Temex Resources Corp. (BN 88941 3084) reassessments for its 2014 and 2015 taxation years (the “Temex Objections”). These Objections all relate to the tax treatment of CEE arising out of the same facts.

    [Name of corporation] also requests that this Notice of Objection be held in abeyance pending resolution of the Temex Objections as it understands that the result of the Temex Objections will impact its dispute.

    You should include a cover letter with your T400A Form – a link to a sample cover letter is here. If you file a Notice of Objection as instructed, we expect the CRA will make the necessary consequential reassessments of your income tax returns if Temex Resources Corp. is partially or entirely successful with its dispute. The second page of the T400A Form explains how to submit your Notice of Objection to the CRA.

  • Applies to individuals that subscribed for flow-through shares of Temex Resources Corp. and received CEE renunciations directly. These individuals would have received a Form T101 indicating the renounced amount.

    The reduction in CEE renounced to subscribers that are individuals will lead to a reassessment of their 2014 taxation year and/or one or more subsequent taxation years.

    When you receive a Notice of Reassessment from the CRA, you should file a Notice of Objection within 90 days of the date noted on the Notice of Reassessment. We expect that your appeal will be held in abeyance pending the outcome of our dispute with the CRA relating to the CEE that was denied.

    The appeals process will take some time to resolve, so we encourage you to pay the accrued tax and interest noted on the Notice of Reassessment – this will stop interest from accumulating on the outstanding balance during the appeals process.

    If Temex Resources Corp. is partially or entirely successful in its dispute with the CRA and you file a Notice of Objection within the 90 day window, you should receive:

    (i) a consequential Notice of Reassessment restoring all or a portion of the CEE renounced effective December 31, 2014;

    (ii) a refund of some or all of the tax and interest you paid in connection with the original Notice of Reassessment; and

    (iii) an additional payment of interest if you paid the original Notice of Reassessment.

    Subscribers who do not file a Notice of Objection within the 90 day window will not be entitled to receive a consequential reassessment, refund or interest payment even if Temex Resources Corp. is partially or entirely successful in its dispute with the CRA.  In addition, such subscribers will not be entitled to an indemnity for taxes paid or payable under the original Notice of Reassessment.

    Subscribers may object by filing a Notice of Objection in a T400A Form – the link to that form is here*. Please fill out the T400A Form with your own personal information according to the instructions. In the box where it asks you to provide the issues, reasons, and all relevant facts for your objection, please include the following language:

    I hereby object to the amounts assessed, penalties and interest and any consequential adjustments in their entirety.  Further facts, reasons and supporting documentation will be provided to an Appeals Officer, as necessary, once one is assigned.

    I request that this Notice of Objection be assigned to the same Appeals Officer as is handling the related Notices of Objection being filed in response to the Temex Resources Corp. (BN 88941 3084) reassessments for its 2014 and 2015 taxation years (the “Temex Objections”). These Objections all relate to the tax treatment of CEE arising out of the same facts.

    I also request that this Notice of Objection be held in abeyance pending resolution of the Temex Objections as I understand that the result of the Temex Objections will impact my dispute.

    You should include a cover letter with your T400A Form – a link to a sample cover letter is here. If you file a Notice of Objection as instructed, we expect the CRA will make the necessary consequential reassessments of your income tax returns if Temex Resources Corp. is partially or entirely successful with its dispute. The second page of the T400A Form explains how to submit your Notice of Objection to the CRA.

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